September 25, 2013
UNITED STATES OF AMERICA, Plaintiff,
ALEJANDRO MUNOZ GALVAN, et al., Defendants.
ERIN J. RADEKIN, Attorney at Law - SBN 214964, Sacramento, California, Attorney for Defendant, ALEJANDRO MUNOZ GALVAN.
BENJAMIN WAGNER, United States Attorney,
HEIKO COPPOLA, Assistant United States Attorney,
SHARI RUSK, Attorney for Defendant, GARARDO CARDENAS.
MICHAEL BIGELOW, Attorney for Defendant, ALEJANDRO PANTOJA-SOLORIO.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Heiko Coppola, defendant, Alejandro Pantoja-Solorio, by and through his counsel, Michael Bigelow, defendant Garardo Cardenas, by and through his counsel, Shari Rusk, and defendant Alejandro Munoz Galvan, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, September 26, 2013 at 9:30 a.m., and to continue the status conference to November 14, 2013 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.
The reason for this request is that the parties need additional time to review discovery and for other defense preparation including investigation and plea negotiations. The Court is advised that all counsel named above concur with this request and have authorized Ms. Radekin to sign this stipulation on their behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until November 14, 2013 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference of September 26, 2013 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on November 14, 2013 at 9:30 a.m. The court finds excludable time in this matter through November 14, 2013 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.